Eleventh Circuit Re-Affirms District Courts’ Discretion to Deny Compassionate Release Solely on § 3553(a) Grounds Despite Post-Sentence Legal Changes

Introduction

On 25 August 2025 the United States Court of Appeals for the Eleventh Circuit decided United States v. Cheddie Lamar Griffin, an unpublished opinion that nonetheless provides timely guidance on how district courts should handle compassionate-release motions filed under 18 U.S.C. § 3582(c)(1)(A) after the 2023 amendments to U.S.S.G. § 1B1.13. The case sits at the intersection of three recurring topics:

• the 2023 Sentencing-Commission amendment that for the first time treats certain non-retroactive statutory changes as potential “extraordinary and compelling reasons” (§ 1B1.13(b)(6)),
• the Eleventh Circuit’s pre-existing rule from United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021), permitting district courts to deny relief on any one of three independent prongs (§ 3553(a) factors, extraordinary reasons, no danger to society), and
• the continuing fallout from Congress’s 2018 First Step Act, which prohibited “stacked” 25-year consecutive sentences for first-time § 924(c) offenders—relief that was not made retroactive.

Defendant-appellant Cheddie Griffin, serving what in total amounts to a de facto life sentence, sought compassionate release based on (i) the § 924(c) sentencing disparity created by the First Step Act, (ii) the new § 1B1.13(b)(6) policy statement, and (iii) his disputed mental impairments. The district court denied relief in a one-paragraph order, relying exclusively on the § 3553(a) factors.

Summary of the Judgment

The Eleventh Circuit affirmed. Applying Tinker, the panel held:

1. Once a district court finds that the § 3553(a) factors do not support release, it need not decide whether the defendant has shown “extraordinary and compelling reasons.”
2. The district court’s brief order sufficiently demonstrated consideration of the pertinent § 3553(a) factors—namely the violent nature of Griffin’s offenses and his extensive criminal history—despite not mentioning each piece of mitigating evidence.
3. No abuse of discretion occurred, even though the district court did not expressly analyze the 2023 amendment to § 1B1.13 or Griffin’s mental-health submissions.

Detailed Analysis

1. Precedents Cited and Their Influence

• United States v. Tinker, 14 F.4th 1234 (11th Cir. 2021) – The cornerstone precedent. Tinker instructs that the three statutory/policy inquiries under § 3582(c)(1)(A) are disjunctive; failure at any step ends the analysis. Griffin’s panel leaned on Tinker to justify the district court’s decision to bypass “extraordinary and compelling reasons.”
• United States v. Bryant, 996 F.3d 1243 (11th Cir. 2021) – Earlier circuit decision refusing to recognize non-enumerated extraordinary reasons until § 1B1.13 was amended. The panel referenced Bryant to show that the district court had previously been correct to deny Griffin’s earlier motions before the 2023 amendment.
• United States v. Giron, 15 F.4th 1343 (11th Cir. 2021) – Provides the de novo standard of review for eligibility questions and abuse-of-discretion standard for merits decisions.
• United States v. Harris, 989 F.3d 908 (11th Cir. 2021) – Restates the limited statutory exceptions to the “finality of sentences” doctrine.
• Supreme Court’s Erlinger v. United States, 602 U.S. 821 (2024) – Cited by Griffin for its holdings on ACCA predicate timing; ultimately irrelevant to the panel’s ruling but indicative of defendants’ new “change-in-law” arguments under § 1B1.13(b)(6).

2. The Court’s Legal Reasoning

1. Sequence Flexibility under Tinker. The panel reiterated that district courts are not forced into a rigid, three-step sequence. If § 3553(a) factors alone defeat the motion, analysis stops; this conserves judicial resources and prevents advisory pronouncements on “extraordinary reasons.”
2. Sufficiency of a “Sparse” Order. To survive appellate scrutiny, a compassionate-release order must merely evidence consideration of the major § 3553(a) themes: (i) nature and circumstances of the offense, (ii) defendant’s characteristics, and (iii) the penological goals of punishment, deterrence, and public protection. The district court’s text order—though short—checked those boxes.
3. Discretion over Weight of Factors. Appellate review for abuse of discretion allows the district court generous leeway in weighing violent conduct and criminal history more heavily than mitigating mental-health evidence or post-sentencing rehabilitation.
4. Non-Retroactivity of § 924(c) “Stacking” Reform. The court implicitly relied on Congress’s refusal to make § 403 of the First Step Act retroactive. Even if § 1B1.13(b)(6) now allows courts to consider non-retroactive changes, nothing in the Guideline requires relief; it merely opens the door. The § 3553(a) factors can still close it.

3. Impact of the Judgment

Although unpublished, the decision tightly weaves recent Sentencing-Commission policy with existing circuit doctrine and therefore carries persuasive value:

• Post-2023 Compassionate-Release Landscape. Defendants invoking new § 1B1.13(b)(6) must still clear the formidable § 3553(a) hurdle. Merely showing a “gross disparity” after First Step reforms does not compel relief.
• Drafting of District-Court Orders. The Eleventh Circuit once again signaled tolerance for concise compassionate-release orders so long as they mention key aggravating factors.
• Strategic Guidance for Litigants. Defense counsel should marshal persuasive § 3553(a) arguments—rehabilitation, medical infirmities, post-sentence conduct—rather than assume that disparity alone will carry the day. The government, for its part, can lean on Griffin to argue that dangerousness and criminal-history concerns justify denial even where extraordinary reasons exist.
• Continued Vitality of Tinker. By reaffirming Tinker in the wake of the 2023 Guideline amendments, the Eleventh Circuit clarified that the amendment did not disturb the sequencing discretion recognized in Tinker.

4. Complex Concepts Simplified

• Compassionate Release (§ 3582(c)(1)(A)) – A statutory mechanism permitting a federal court to reduce a final sentence if three conditions are met: (1) § 3553(a) factors favor reduction; (2) “extraordinary and compelling reasons” exist; and (3) the defendant is not a danger to society.
• § 3553(a) Factors – The sentencing “checklist” requiring courts to consider punishment, deterrence, public safety, rehabilitation, and the seriousness of the crime.
• § 1B1.13(b)(6) (2023 Amendment) – New Guideline allowing courts to deem certain non-retroactive changes in law as an “extraordinary and compelling reason” if they create a “gross disparity” and the prisoner has served at least ten years.
• § 924(c) “Stacking” – Prior to 2018, multiple firearm counts in a single indictment triggered consecutive 7-year and 25-year mandatory minimums. The First Step Act ended “stacking” by reserving the 25-year enhancement for subsequent prosecutions but refused retroactivity.
• Non-Argument Calendar – A procedural device for cases deemed suitable for decision without oral argument, typically because existing precedent controls.

Conclusion

United States v. Griffin offers a timely reminder that the new, defendant-friendly language of § 1B1.13(b)(6) is not a silver bullet. District courts remain free—indeed required—to weigh public-safety concerns and the traditional sentencing factors when faced with motions for compassionate release. As long as the record reflects that those factors were considered, even a brief order of denial will survive appellate review. The Eleventh Circuit’s decision solidifies the practical hierarchy in compassionate-release litigation: § 3553(a) first, everything else—no matter how compelling—second.